ML20057C329
| ML20057C329 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/09/1993 |
| From: | Holmesray P, Landis K, Schin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C317 | List: |
| References | |
| 50-302-93-21, NUDOCS 9309280220 | |
| Download: ML20057C329 (11) | |
See also: IR 05000302/1993021
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UMITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET, N.W;, SUITE 2300
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ATLANTA, GEORGIA 303234199
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Report No.:
50-302/93-21
Licensee:
Florida Power Corporation
'3201 34th Street, South
St. Petersburg, FL 33733
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Docket No.:
50-302
License No.: DPR-72
Facility Name:
Crystal River 3
Inspection Conducted: .luly 11 - August 14, 1993
Inspector:
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Q3
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P.Holm~es-RayTSeniorRepdentInspector
Da'tgSiged
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Inspector:
I3
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R. Schin,' Project Engineer, Ril
Date' Sfgned
Approved by:
IN Y
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K. Landis, Section Chief
Date Signed
Division of Reactor Projects
SUMMARY
Scope:
This routine inspection was conducted by the resident inspector and a regional
inspector in the areas of plant operations, security, radiological controls,
maintenance / surveillance, and Licensee Event Reports.
Numerous facility tours
were conducted and facility operations observed.
Backshift inspections were
conducted on July 17, 23, 24, 27, 30 and August 7, 1993.
Results:
In the area of plant operations, one violation was identified regarding
inadequate short term corrective action to prevent the reccurrence of the
improper operation of Decay Heat Valve DCV-177 and the Reactor Coolant System
overcooling event of March 5,.1993. (Paragraph 3.a).
In the area of maintenance / surveillance, one Non-cited violation was
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identified regarding inadequate restoration from a surveillance. (Paragraph 4)
In the area of self assessment, three' examples of aggressive self assessment
were observed by the inspector during this reporting period. (Paragraph 3.b)
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9309280220 930909
ADOCK 05000302
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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J. Alberdi, Manager, Nuclear Plant Operatiens
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- G. Becker, Manager, Site Nuclear Engineering Services
G. Boldt, Vice President Nuclear Production
R. Davis, Manager, Nuclear Plant Maintenance
- E. Froats, Manager, Nuclear Compliance
G. Halnon, Manager, Nuclear Plant Systems Engineering
- S. Johnson, Manager, Chemistry and Radiation Protection
- B. Hickle, Director, Nuclear Plant Operations
W. Marshall, Nucleer Operations Superintendent
- L. Moffatt, Manager, Nuclear Plant Technical Support
- P. McKee, Director, Quality Programs
- R. McLaughlin, Nuclear Regulatory Specialist
B. Moore, Manager, Nuclear Integrated Scheduling
- S. Robinson, Manager, Nuclear Quality Assurance
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- W. Rossfeld, Manager, Site Nuclear Services
- R. Widell, Director, Nuclear Operations Site Support
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- K. Wilson, Manager, Nuclear Licensing
Other licensee employees contacted included office, operations,
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engineering, maintenance, chemistry / radiation, and corporate personnel.
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NRC Inspectors
- K. Landis, Section Chief, DRP 2B, Region II
- P. Holmes-Ray, Senior Resident Inspector
- Attended exit interview
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Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Plant Status and Activities
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The plant continued in power operation (Mode 1) for the duration of this
inspection period.
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During the week of July 23, an inspection in the area of. control of
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special material was conducted by a specialist inspector from Region II.
The results of the inspection will be documented in NRC Inspection
Report 50-302/93-19.
On July 29 and 30 the Deputy Director, Division of Reactor Safety and
the Section Chief, Division of Reactor Projects Section 2B were on site
for the exit meeting of NRC Electrical Distribution System Functional
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Inspection and a site tour.
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3.
Plant Operations (71707, 93702, & 40500)
Throughout the inspection period, facility tours were conducted to
observe operations and maintenance activities in progress. The tours
included entries into the protected areas and the radiologically
controlled areas of the plant.
During these inspections, discussions
were held with operators, health physics and instrument and controls
technicians, mechanics, security personnel, engineers, supervisors, and
plant management. Some operations and maintenance activity observations
were conducted during backshifts.
Licensee meetings were attended by
the inspector to observe planning and management activities.
The
inspections confirmed FPC's compliance with 10 CFR, Technical
Specifications, License Conditions, and Administrative Procedures.
a.
Operational Events
Decay Heat Closed Cycle Cooling Heat Exchanger Outlet Valve (DCV-
177)
During a tour of the
"A" Decay Heat Pit, the inspector noted an
apparently bent manual handwheel stem on DCV-177. DCV-177 is an
air operated valve, and the handwheel is for backup use in the
event of a failure the air operator.
Inspector followup of this
with the system engineer determined that the handwheel stem was
bent, but that the handwheel turned sufficiently freely. While
the engineer was turning the handwheel (with its coupling lever
disengaged), the inspector observed how the handwheel and
handwheel coupling lever moved; imagined how the valve stem, air
actuator stem, and valve air actuator stem pin would move through
the range of travel of the valve; and compared this to the
recently posted new manual valve operating instructions for taking
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manual handwheel control of the valve. The instructions stated:
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1)
Rotate handwheel to line up lever with coupling and engage
2)
Isolate instrument air (I.A.)3 but do not vent at this time
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3)
Remove valve stem pin
4)
Vent I.A.
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The inspector concluded that, in any valve position other that
full open, step three of this procedure (remove valve stem pin)
could not physically be performed, because the location of a steel
plate behind the valve stem pin would prevent its removal. The
engineer agreed that in some valve positions the valve stem pin
could not be removed. He could not refute the inspector's
contention-that the steel plate would prevent removal of the valve
stem pin in any valve position other than full open.
The engineer
stated that he had identified other problems with manual operation
of the valve. On a similar valve he had set up for operator
training on the new instructions, he had rotated the air actuator
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stem by 90 degrees to eliminate the steel plate interference with
the removal of the stem pin. However, operators still could
sometimes not remove the stem pin because of tension from the air
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actuator spring (with instrument air isolated, a continuous air
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bleed off allowed the spring to push the air actuator stem up
toward the failed full open position). He had proposed a valve
operator modification as the only way to ensure the ability to
manually operate the valve with the handwheel.
The inspector observed that the Decay Heat Cooling Heat Exchanger
Bypass Valve, DCV-17, which was also in the ' A' Decay Heat Pit,
was similar to DCV-177 and had the same new instructions for
manual operation and the same problem with a steel plate
preventing stem pin removal. The engineer stated that the
corresponding "B" train valves, DCV-178 and DCV-18, were the same
and would have the same problem.
Failure of the automatic operator of DCV-177 and operator
inability to manually operate the valve with the handwheel had
caused an overcooling event with the plant in Mode 4 (and
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switching to Decay Heat cooling) on March 5, 1993. The licensee
had written LER 93-01 and supplemental LER 93-01-01 on this event.
Also, the NRC had issued Violation 50-302/93-09-01 for inadequate
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locally posted procedures for manual operation of DCV-177. During
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this event, the operator could not remove the stem pin even with
the valve full open.
In the LER, the licensee stated that the
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operator's inability to remove the stem pin was probably due to
corrosion on the pin. The engineer stated that, to his knowledge,
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that stem pin had not been removed since the event and could still
be rusted in place.
The LER stated that instructions for assuming manual control of
valve DCV-177 had contributed to the overcooling event. The
problem with those instructions was that they caused the valve to
reposition full open, resulting in overcooling of the Reactor
Coolant System. The licensee's LER and violation response stated
that those instructions for assuming manual control of DCV-177
(and similar valves servicing the Decay Heat Coolers) had been
replaced with interim instructions for taking manual control of
the valve without repositioning it to the full open position. The
new interim instructions were the ones the inspector concluded
would not work if the valve were in any position other than full
open.
The inspector visited DCV-177 again with a camera and an Assistant
Nuclear Operator. The ANO agreed that the posted instructions
would not work because stem pin removal was blocked by a steel
plate in all valve positions other than full open.
He stated that
he had not previously been aware of this condition, and assisted
the inspector in taking photos of DCV-177 and DCV-17. The
operator also stated that he had received the training on the new
instructions (on the valve with the air actuator stem rotated 90
degrees), and concluded that removal of the stem pin was very
difficult at best.
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The inspector described his concern to the NSS with the aid of
photos of the valve that the inspector had just taken, informed
the NSS that the currently posted instructions for manual
operation of DCV-177 were inadequate because they could not be
performed in an intermediate valve position (and maybe not in any
valve position), and reminded him that having inadequate
instructions posted for the operation of safety-related equipment
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was not acceptable. The inspector also expressed a concern that
operators were not fully aware of the problems with manual
operation of DCV-177 and other similar valves. The NSS stated
that he had received the training on the new instructions (on the
valve with the air actuator stem rotated 90 degrees) and had
concluded that they would not work. Another SR0 stated that he
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had also received the training (he was able to remove the stem
pin) and that the instructor had said that the stem pin
orientation on the valves in the plant was different, such that
the stem pin could not be removed in some valve positions.
Later that day, the system engineer and operators attempted to
engage the DCV-177 handwheel coupling lever (with the valve in the
full open position) and could not.
They initiated a maintenance
work request to adjust the handwheel stop so that it could be
rotated sufficiently to engage the coupling lever while DCV-177
was in the full open position.
The system engineer had performed " Failure Analysis No. 93-DCV-
177-0 (for DCV 177)" in which he had proposed a modification to
reorient the stem pins on the valves in the plant (DCV-177, DCV-
178, DCV-17, and DCV-18) to provide access for stem pin removal.
This failure analysis had been distributed to top managers in
Operations, Maintenance, Engineering, and Compliance. The
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proposed modification, as further documented in REA 930672, was in
the review process, where an alternate modification was being
recommended - installation of a handwheel directly on top of the
air actuator.
This alternate modification would eliminate the
existing handwheel, coupling lever, and valve stem pin.
Prior to
the end of the report period, the licensee initiated action to
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expedite the alternate modification, so that it could be completed
within about three months.
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The inspector reviewed the safety importance of the ability to
operate valves DCV-177, DCV-178, DCV-17, and DCV-18 with their
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manual handwheels. The safety positions of these valves (DCV-177
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and DCV-178 open, DCV-17 and DCV-18 closed) were the positions in
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which they were kept during plant operation at power and also the
positions to which they would fail upon loss of control air. The
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Emergency Operating Procedures did not require operation of these
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valves from their safety positions or any handwheel operation of
the valves. The valves were operated in mid-positions for decay
heat removal only when the plant was shut down.
During shutdown
decay heat removal, if the air actuator of one of the valves
should fail, operators could switch to the other train of decay
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heat cooling instead of attempting to operate the failed valve
with its handwheel. The inspector concluded that operation of the
plant for about three months without functional manual handwheels
for these four valves was not unsafe, if operators were properly
trained.
The inadequate manual valve operating instruct 4ns for DCV-177
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(and other similar valves) will be tracked as VIO 50-302/93-21-01:
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Inadequate corrective action for inadequate locally posted
procedures for manual operation of DCV-177.
b.
Self Assessment
(1)
During this reporting period the inspector attended several
PRC meetings to observe the conduct of the meeting, the
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makeup of the committee, and the topics reviewed. The
meetings were conducted in a formal and professional manner
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by a quorum of qualified personnel from diverse disciplines.
The agenda was followed and the presentations were thorough.
Not all proposals were accepted by the PRC. The inspector
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concluded that PRC was functioning in a manner that promotes
plant safety.
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(2)
On July 13, 1993, the licensee's Quality Programs Department
issued a Nonconformance Report the subject of which was
Inadequate System Configuration Control. This report was
generated to bring into focus the problem of system
configuration control at Crystal River 3.
In the last 13
months there have been 13 Problem Reports issued having to
do with system configuration control. The report stated:
"Although contributing causes have been determined for each
individual event, a larger more widespread programmatic
problem appears to exist and requires a more in-depth root
cause investigation and corrective action." Also, on July
13, 1993, the Quality Systems trending section provided to
the DNP0 an analysis of problem reports attributed to
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personnel error by operations personnel for the period July
1,1992 to July 1,1993. This analysis showed that 40%
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involved use of procedures, 33% involved valve
mispositioning, and 27% were related to general work control
issues.
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As this reporting period ends, the licensee's corrective
action to resolve the personnel error problem is in its
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formative stage with the first step, to make plant personnel
aware of the issue, taken. The inspector will follow the
progress of this proactive effort by the licensee to reduce
personnel error.
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(3)
A Quality Programs Evaluation Report titled " Violent
Weather" was issued on July 26, 1993. This report was to
determine the readiness to adequately respond to violent
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weather using lessons learned as provided in the jointly
sponsored INPO and NRC Report "Effect of Hurricane Andrew on
the Turkey Point Nuclear Generation Station from August 20 -
30, 1992." Although this evaluation concluded that CR3 was
prepared to adequately respond to violent weather, there
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were several recommendations to improve the readiness to
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respond to violent weather.
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The inspector concluded that the licensee was actively involved in
self assessment and that, if the recommendations generated by this
effort are evaluated and acted upon, increased plant and site
safety would result.
e.
Radiological Protection Program
Radiation protection control activities were observed to verify
that these activities were in conformance with the facility
policies and procedures, and in compliance with regulatory
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requirements. These observations included:
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Entry to and exit from contaminated areas, including step-
off pad conditions and disposal of contaminated clothing;
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Area postings and controls;
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Work activity within radiation, high radiation, and
contaminated areas;
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RCA exiting practices; and
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Proper wearing of personnel monitoring equipment, protective
clothing, and respiratory equipment.
The implementation of radiological controls observed during this
inspection period were proper and conservative.
f.
Security Control
In the course of the monthly activities, the inspector included a
review of the licensee's physical security program. The
performance of various shifts of the security force was observed
in the conduct of daily activities to include: protected and
vital areas access controls; searching of personnel, packages, and
vehicles; badge issuance and retrieval;' escorting of visitors;
patrols; and compensatory posts.
In addition, the inspector
observed the operational status of protected area lighting,
protected and vital areas barrier integrity, and the security
organization interface with operations and maintenance. No
performance discrepancies were identified by the inspectors.
g.
Fire Pr9tection
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fire protection activities, staffing, and equipment were observed
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to verify that fire brigade staffir>t was appropriate and that fire
alarms, extinguishing equipment, actuating controls, fire fighting
equipment, emergency equipment, and fire barriers were operable.
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One violation was identified in the Plant Operations area (paragraph
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3.a).
4.
Maintenance and Surveillance Activities (62703 & 61726)
Surveillance tests were observed to verify that approved procedures were
being used; qualified personnel were conducting the tests; tests were
adequate to verify equipment operability; calibrated equipment was
utilized; and TS requirements appropriately implemented.
The following tests were observed and/or data reviewed:
- SP-ll3,
Power Range Nuclear Instrumentation Calibration;
- SP-310,
LPMS Channels Assessment;
- SP-312A, Daily Heat Balance Power Comparison;
- SP-321,
Power Distribution Breaker Alignment and Power Availability
Verification;
- SP-340E, DHP-1B, BSP-1B and Valve Surveillance; and
- SP-354, Monthly Functional Test of the Emergency Diesel Generator.
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In addition, the inspector observed maintenance activities to verify
that correct equipment clearances were in effect; work requests and fire
prevention work permits, as required, were issued and being followed;
quality control personnel performed inspection activities as required;
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and TS requirements were being followed.
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Maintenance was observed and work packages were reviewed for the
following maintenance activities:
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WR 295577, repair DHV-70;
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WR 312849, replace SFV-27;
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WR 307401, control room cabinet filter maintenance;
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WR 312175, raw water system transducer mock-up; and
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WR 297316, repair / replace DHV-69.
One item was considered noteworthy - An inadequate procedure resulting
in a valve not being restored to the' correct position after
surveillance.
On July 15, 1993, the licensee, during performance of surveillance
procedure SP-340B; DHP-1A, BSP-1A and Valve Surveillance; valve BSV-6
was found open vs sealed shut as required by SP-381, Locked Valve List.
The licensee's investigation determined that.BSV-6 had been left open
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following the performance of SP-340E; DHP-1B, BSP-1B and Valve
Surveillance; on June 19, 1993.
BSV-6 being open caused no system
degradation since all other valves were in the correct position and
therefore there was no flow path through BSV-6. The cause of BSV-6 being
out of the desired position was an inadequate procedure.
SP-340B and
SP-340E perform the same surveillance on A & B trains of Decay Heat and
Building Spray systems.
In the restoration enclosure for each procedure
both BSV-5 and BSV-6 were to be verified " sealed / closed". Since onl'
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one of the valves was opened to perform either surveillance; the B train
valve (BSV-6) was deleted from the A train procedure and the A train
valve (BSV-5) was to be deleted from the B train procedure. When the
change to the B train surveillance was issued it deleted the wrong
valve. This improper change resulted in BSV-6 not being sealed / closed
when SP-340E was performed on June 19, 1993. Upon discovery the
licensee sealed / closed BSV-6 and when the cause of the valve being out
of position was determined, revised SP-340E to include BSV-6 in the
restoration enclosure. As mentioned in paragraph 3.b(2) of this report,
the licensee has initiated a broad scope investigation to determine the
cause of the recent personnel errors and to recommend appropriate
corrective actions. This licensee identified violation is not being
cited because criteria specified in Section VII.B. of the NRC
Enforcement Policy were satisfied. This item will be identified as NCV
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50-302/93-21-02:
Inadequate surveillance procedure resulting in valve
misalignment.
Overall, surveillance and maintenance activities observed and discussed
above were performed in a satisfactory manner in accordance with
procedural requirements and met the requirements of the TS.
5.
Review of Licensee Event Reports (92700)
LERs were reviewed for potential generic impact, to detect trends, and
to determine whether corrective actions appeared appropriate.
Events
that were reported immediately were reviewed as they occurred to
determine if the TS were satisfied.
LERs were also reviewed in
accordance with the current NRC Enforcement Policy.
a.
(Closed) LER 92-13:
Incorrect Valve Stem Material Causes
Inoperable Containment Isolation Valve
On June 2,1992, with the plant in Mode 6, makeup isolation valve
MUV-27 failed to close on demand during post-maintenance testing.
The licensee determined the cause to be incorrect valve stem
material (316 stainless steel vs. A564-GR630-H1150, which has
superior tensile and yield characteristics).
Plant records showed
that a modification had been scheduled to change the valve stem
material but had not been accomplished. The licensee installed
the correct stem material in MVV-27 and reviewed plant records to
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identify other valve stems that may not have been replaced per the
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intent of the original modification. This review along with
physical inspections identified several other 316 stainless steel
valve stems that had not been upgraded.
Engineering analysis of
each determined that the 316 material was acceptable in those
applications as installed. Drawing changes were initiated as
needed. The inspector reviewed records of the completed
modification to MUV-27 and the review and engineering analysis of
other valves. This LER is closed.
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b.
(Closed) LER 92-25:
Surveillance Scheduling Method Causes Failure
to Complete Surveillance Procedure Within the Required Interval,
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Resulting in a Condition Prohibited by Technical Specifications
On November 23, 1992, plant personnel discovered that a monthly
surveillance (channel functional test) of the "A" train toxic gas
monitoring had not been performed within its required time. The
cause was that the surveillance schedule showed only a quarterly
surveillance (channel calibration) that would satisfy the
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requirement for the monthly surveillance, and the schedule did not
show the monthly surveillance. The 25% allowable time extension
for a quarterly exceeds that of a monthly interval.
For
corrective action, the surveillance schedule was revised to
include both monthly and quarterly surveillar.ces.
The inspector
reviewed the revised surveillance schedule (SP-443, Master
Surveillance Plan, Rev. 99, of March 17,1993). This LER is
closed.
Violations or deviations were not identified.
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7.
Exit Interview
The inspection scope and findings were summarized on August 24, 1993,
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with those persons indicated in paragraph 1.
The Senior Resident
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Inspector accompanied by his Section Chief, described the areas
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inspected and discussed in detail the inspection results listed below.
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Proprietary information is not contained in this report. Dissenting
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comments were not received from the licensee.
Item Number
Status
Description and Reference
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VIO 50-302/93-21-01
Open
Inadequate corrective action for
inadequate locally posted procedures
for manual operation of DCV-177.
(paragraph 3.a)
NCV 50-302/93-21-02
Closed
Inadequate surveillance procedure
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resulting in valve misalignment.
(paragraph 4)
LER 50-302/92-13
Closed
Incorrect valve stem material causes
inoperable containment isolation
valve.
(paragraph 5)
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LER 50-302/92-25
Closed
Surveillance scheduling method
causes failure to complete
surveillance procedure within the
required interval, resulting in a
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condition proh G ted by technical
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Specifications.
(paragraph 5)
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Acronyms and Abbreviations
- Auxiliary Nuclear Operator
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CFR
- Code of Federal Regulations
- Decay Heat Closed Cycle Cooling Valve-
DNP0 - Director Nuclear Operations
- Florida Power Corporation
FSAR - Final Safety Analysis Report
- Instrument Air
INPO - Institute for Nuclear Power Operation
LER
- Licensee Event Report
- Non-cited Violation
NRC
- Nuclear Regulatory Commission
- Nuclear Shift Supervisor
- Plant Review Committee
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- Radiation Control Area
REA
- Request for Engineering Assistance
- Surveillance Procedure
TS
- Technical Specification
- Violation
- Work Request
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